HEFCE publishes PREVENT monitoring framework

HEFCE has today published its monitoring framework for the PREVENT duty, along with a practical “non-statutory” advice note on areas to think about.

The monitoring framework follows the structure set out in the consultation, but now with dates for compliance as follows:



Initial self assessment
All Relevant Higher Education Bodies (RHEBs)
22 January 2016
Submission of detailed material
HEFCE-funded providers
1 April 2016
Alternative providers with specific course designation
1 June 2016
All other RHEBs
1 August 2016
Annual report on implementation
HEFCE-funded providers
1 December 2016
All other RHEBs
1 February 2017
Cyclical reviews
All providers
Once every five years

Where provision is franchised by an RHEB it is expected to ensure that appropriate arrangements are in place at the partner organization for its students. The suggestion is made that the processes at both organisations should be aligned. This may be easier said than done. For example, in the case of partnerships with FE colleges and schools, the colleges and schools will be subject to OFSTED monitoring of their PREVENT compliance, and are likely to be unwilling to modify that approach to align it with an RHEBs. At the very least, RHEBs and their partners will need to consider how to address this in the franchise agreement.

Validation is more straightforward with the validated partner being responsible for its own provision.

The framework makes the point that the PREVENT duty does not apply to activity in other countries, so neither overseas campuses not TNE are on the face of it caught. However, there will clearly need to be some thought given to risks created by the transfer of staff and students between campuses and programmes and joint events.

Along with the action plans, risk assessment and summary of institutional arrangements on compliance with the PREVENT guidance, RHEBs are asked to provide data on the following, initially on a voluntary basis and then as an expected part of the annual report:

  • Number of CHANNEL referrals
  • Number of events and speakers referred to the highest levels of approval
  • Number of staff who received PREVENT related training, and type of training received.

Quantative data of this sort may be difficult to interpret given how sensitive it is to an institution’s risk appetite. We have already seen reports of zealous over-reaction to the duty by some providers and the numbers of referrals by schools has risen steeply since the duty came in to force, albeit that 80% of those referred were subsequently of no interest to CHANNEL deradicalisation officers. There is a risk of disproportionate referrals, which, when reported as part of the data streams above, may give the impression of a far bigger problem than is the case.

One of the most interesting aspects of the monitoring framework is the fact that it will necessitate substantive assessments by HEFCE of whether or not a particular RHEB’s approach to compliance with the PREVENT duty is robust and fit for purpose. The framework recognizes that this may necessitate HEFCE telling BIS of any concerns, who may in turn refer it to the Home Office for further action. This is a rather different role to the one HEFCE has traditionally adopted.

The annual return will require governing bodies to sign a series of declarations to the effect that the PREVENT duty has been complied with, that all required information has been provided to HEFCE and all serious issues have been reported. These declarations reflect the fact that governing bodies are expected to be engaged in and to lead in this process. There will be a need for targeted briefings, reports to and discussions with governing bodies to ensure they are confident in signing these declarations, as the consequences of signing them without being satisfied as to their correctness could be serious, both for the institution and for members of governing bodies too.

Smita Jamdar 
Partner and Head of Education
T: 0121 214 0332
E: smita.jamdar@shma.co.uk
W: www.shma.co.uk


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